Pro-CME Privacy Policy
Effective August 8, 2018
Pro-CME is a service mark of Doctor’s Guide Publishing Limited.
Doctor’s Guide Publishing Limited, 7A rue Robert Stumper, L-2557, Luxembourg (“we”) is committed to protecting the privacy of the personal information that you share with us. In this Privacy Policy, we provide information about how we collect, process and share personal information through websites, mobile applications and newsletters that Pro-CME operates (“Services”). This Privacy Policy only applies to Services that include a link to this Privacy Policy and may be supplemented by additional notices to you depending on the specific Service you are accessing or using. By “personal information” or “personal data”, we mean information that identifies you or can reasonably be used to identify you. If you are located in the European Economic Area, please also see the Supplemental European Online Privacy Statement below.

1. Collection of Personal Information From Users of our ServicesInformation You Actively Submit. We collect certain types of personal information when you interact with our Services, such as when you:

Register for an account on any Service or update your profile information;

Participate in a medical education program;

Respond to an online survey;

Request information from us about patient assistance resources, medical education programs and other medical communications;

Submit comments, reviews, or other user-generated content on our Services;

Request customer or technical support from us; or

Otherwise submit personal information to us via the Services.

The personal information we collect includes your name, email address, mailing address, telephone number, certain information related to your profession (e.g., specialty, education, hospital affiliation, etc.) and any other personal information that you actively submit to us. In each such instance, you will know what personal information we collect, because you actively submit it. We endeavor to clearly label which information is required and which information is optional in all cases. If you are unable or choose not to provide us with the personal information we reasonably require, we may be unable to provide you with the information or services you have requested.Information Passively Submitted. When you use our Services, we may also passively track information about your computer, device or Internet connection, such as the IP address of your computer and/or Internet service provider, the date and time you access our website, the Internet address of websites from which you come to our websites, the type of device you are using to access the Service, the Web browser and operating system you are using, and your movements and interactions on our Services. This data is generated and collected automatically, as part of the standard operation of the Services. Unless you also actively submit personal information to us, any information that is passively submitted typically does not allow us to identify you personally.Publicly Available Information. Where permitted by applicable law, we may also collect information about your specialty, hospital affiliation and academic or scientific publications from public resources.Cookies and Web Beacons. We may place cookies on users’ computers. Cookies can save data about individual users, such as the user's name, password, username, screen preferences, and the pages of a site viewed by the user. When the user revisits the website, we may recognize the user based on any cookies placed on their computer and customize the user's experience accordingly. For more information about our use of cookies, please see our Cookie Policy.
We may also use web beacons to track who has opened our emails. Web beacons are tiny graphic image files, embedded in a website page that notify the home server (which can belong to the host website, a network advertiser, or some other third party) on a non-personally identifiable basis that some interaction has taken place. This notice may also result in a cookie being set on your device, as described above.Use of Personal Data Collected
We use personal information that we collect about you through the Services to:

Upon request, create an account for you for the Services;

Respond appropriately to your inquiries;

Update you regarding your account;

Provide you with a customized experience in connection with our Services;

Discharge our contractual obligations to you; and

Comply with any legal obligations that apply to us.

To the extent permitted by applicable law, including in accordance with your consent where required by applicable law, we also use your personal information for the following purposes:

Invite you to participate in online medical education programs, including accredited continuing medical education programs, and other medical communications activities by email. If you do not wish to receive such emails, you may opt out by following the opt-out instructions included in such emails. We may also invite you via postal mail.

Invite you to learn more and request information from us about patient assistance resources, such as sample programs and co-pay incentive programs. If you do not wish to receive such emails, you may opt out by following the opt-out instructions included in such emails.

Send you medical newsletters including the top medical news in your field of interest and medical alerts. If you do not wish to receive such emails, you may opt out by following the opt-out instructions included in such emails.

Send you invitations to complete market research surveys, by email, typically in exchange for honoraria. If you do not wish to receive such emails, you may opt out by following the opt-out instructions included in such emails.

Review the information provided by you and obtained from public resources to complete your profile and better understand which medical news, education programs and surveys may be of most interest to you.

We also perform statistical analyses of the users of our Services to improve the content, design and navigation of the Services. In these cases, we use aggregate or statistical data that cannot reasonably be used to identify you.
If you respond to a survey, we only use your personal information in connection with your survey responses for the purposes of: (i) verifying your eligibility to participate in a study; (ii) validating your identity and responses for the purposes of preventing duplicate or fraudulent responses; and/or (iii) processing your honoraria payment. Unless we have obtained your explicit consent, we anonymize survey results before sharing them with third parties, although we may be required by applicable law to identify a particular respondent to comply with applicable legal requirements, such as adverse events reporting requirements.

2. Sharing of Information

We do not share your personal information with others, except in the following circumstances and in accordance with applicable law:

With your consent;

To our agents and service providers, who act on our behalf and under confidentiality agreements to deliver services, provide IT support, and help us fulfill the other purposes set forth above;

To our affiliates and partners under confidentiality agreements who work with us to improve our and their services and business practices;

If you participate in a medical education program that we sponsor and thereby obtain a continuing medical education or similar certificate, we may disclose the fact that you participated in the program to the institute or university that accredited the program for the purposes of complying with professional accreditation recordkeeping requirements;

As required by applicable law, including, without limitation, in response to any government or regulatory agency request, to cooperate with law enforcement investigations, or upon receipt of any court order; and

To courts and public authorities to protect you, us, or third parties from harm, such as fraud.

If you respond to a market research survey, we do not share your personal information with the third parties on whose behalf we are conducting such research except with your consent or where required by applicable law, such as to comply with applicable adverse incident reporting requirements. We otherwise only share market research results with third parties in aggregate (as a collection of total responses), and individual responses of respondents are not shared in association with the respondent’s personal information.

3. Security Measures

We take reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We have implemented technical and administrative security features to help prevent the unauthorized release of or access to personal information. Please note, however, that while we have endeavored to create a secure and reliable site for users, the confidentiality or accuracy of any communication or material transmitted to/from us over the Internet cannot be guaranteed. You are responsible for the security of information that you transmit via the Internet. It is your responsibility to safeguard the username and password that you use to access our websites, if any, and to notify us immediately at the contact information below if you ever suspect that your username and/or password has been compromised.

4. Opt-Out Right and Updating Account Information

If you would like to opt out of receiving invitations to medical education programs, medical surveys or medical newsletters from us, please click the opt-out link at the bottom of our emails. Even after you opt out or update your preferences, however, please allow us sufficient time to process your preferences. It may take up to 10 days to process your email related requests, and up to 30 days for all other requests. Even after you have opted out of receiving invitations to medical education programs, medical surveys and medical newsletters from us, we may still contact you for transactional or informational purposes. These include, for example, customer service issues or any questions regarding a specific inquiry you made to us.
If you believe any information we have about you is no longer accurate or current or would like to access personal information we may have about you, please contact us by emailing Privacy@pro-c.me. Upon authenticating your request, we will update or amend your information, or provide you with access, but we reserve the right to use personal information obtained previously to verify your identity or take other actions that we believe are appropriate.

5. Collection of Personal Data From Children
We do not knowingly collect personal information from children under the age of 13, and we do not knowingly market the Services or any goods or services to such children.

6. Contacting Us
If you have any questions regarding this Privacy Policy, you may contact us by emailing Privacy@pro-c.me.

7. Effective Date and Changes to Privacy Policy

We reserve the right to change this Privacy Policy. If we make a material change to how we collect, use, or disclose Personal Information, we will prominently post an updated Privacy Policy on our Services. Where required to do so by law, we may seek your prior consent to any material changes we make to this Privacy Policy. If you disagree with our Privacy Policy changes, you may discontinue using the Services.

Supplemental European Privacy Statement

European Union Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“EU GDPR”), requires Doctor’s Guide Publishing Limited as the data controller to provide additional and different information about its data processing practices to data subjects in the European Economic Area (“EEA”). If you are accessing the Services from a member state of the EEA, this Supplemental European Online Privacy Statement applies to you in addition to the Online Privacy Statement.

We process your personal data on several different legal bases, as follows:

Based on necessity to perform contracts with you (see Article 6(1)(b) of the EU GDPR): When you access, use or register for Service, you form a contract with Pro-CME based on the applicable terms of use or terms of service. We need to process your personal data to discharge our obligations in any such contract, fulfill your requests and orders, answer questions and requests from you, and provide tailored customer support.

Based on compliance with legal obligations (see Article 6(1)(c) of the EU GDPR): We may need to process your personal data to comply with relevant laws, regulatory requirements and to respond to lawful requests, court orders, and legal process.

Based on our legitimate interests (see Article 6(1)(f) of the EU GDPR): We process your personal data to send you invitations to relevant medical education activities (unless you have opted out), medical newsletters (unless you have opted out), invitations to relevant market research surveys (unless you have opted out), understand which products and services may be relevant to you and generally improve our products, services and business practices.

Based on consent (see Article 6(1)(a) of the EU GDPR): We process your personal data on the basis of your consent in various instances, such as with respect to cookies that are not strictly necessary. You may withdraw such consent at any time, without affecting the lawfulness of processing based on consent before such withdrawal.

2. Disclosures to Affiliates
In accordance with applicable law, Pro-CME may disclose your personal data to its affiliates who act as data controllers for the purposes of improving Pro-CME and their products, services and business practices. Please contact us at Privacy@pro-c.me for information about our affiliates and, if applicable, their GDPR-specific representative and data protection officer.

Personal Data Transfers Outside of the EEA
Some recipients of your personal data are located in the following country outside of the EEA for which the European Commission has issued adequacy decisions: Canada. In this case, the transfer is thereby recognized as providing an adequate level of data protection from a European data protection law perspective (pursuant to Article 45 of the EU GDPR).
Some recipients of your personal data are located in the following countries for which the European Commission has not issued an adequacy decision in respect of the level of data protection there: The U.S. (where the recipient is not Privacy Shield certified) and Mexico. By entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU and/or 2004/915/EC) as referred to in Article 46(5) of the EU GDPR or other adequate means, we have established that all such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer (including to our affiliates outside the EEA) is subject to appropriate onward transfer requirements as required by the applicable contract or law.
You can ask for a copy of such appropriate data transfer agreements by contacting us as set out at the bottom of this notice.

3. Data Retention
We will delete, erase or anonymize your personal data within one month after your personal data is no longer necessary for us to provide you with any information or services you have requested, pursue any of the legitimate interests specified herein where the legitimate interest is not overridden by your fundamental rights or privacy interests, comply with any legal obligations to which we are subject, or defend any legal claim against us or support any legal claim made by us, including any potential appeal.

4. Data Subject Rights
Under the conditions set out under applicable law (i.e., the EU GDPR), you have the following rights:

Right to withdraw your consent: If you have declared your consent regarding certain types of processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.

Right of access: You have the right to obtain from us confirmation as to whether your personal data is being processed, and, where that is the case, to request access to the personal data. The access information includes, among other things, the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. You have the right to obtain a copy of the personal data undergoing processing. Subject to applicable law, we may charge a reasonable fee for copies, based on administrative costs.

Right to rectification: You have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to erasure: You have the right to ask us to erase your personal data to the extent it is not required for legally required purposes.

Right to restriction of processing: You have the right to request restriction of processing of your personal data, in which case, it would be marked and processed by us only for certain purposes.

Right to data portability: You have the right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit the personal data to another entity without hindrance from us.

Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data. If you have a right to object and you exercise this right, your personal data will no longer be processed for such purposes by us. Exercising this right will not incur any cost. Such a right to object may not exist, in particular, if the processing of your personal data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

Right to Submit Complaints: You have a right to lodge a complaint with a supervisory authority.

Please note that these rights may be limited under the applicable national data protection law. To exercise your rights please contact us as stated below.

5. Your Choices
You are not required to provide any personal data to Pro-CME, but if you do not provide any personal data to us, you may not be able to use or receive the Services. You can use the Services without consenting to cookies that are not strictly necessary; the only consequence is that the Services will be less tailored to you.

6. Contact Us
For more information or to exercise your rights as described herein, please contact us at Privacy@pro-c.me